This document instructs OSHA compliance officers on how to consistently inspect roadway and highway work zones. To help avoid OSHA citations and penalties, download the document and become familiar with the minimum requirements.

Note that:

The OSHA CPL refers to requirements in part VI of the Manual on Uniform Traffic Control Devices (MUTCD) 1988 revision 3 and 2000 Millenium editions. There is a more current MUTCD version (2009). Among these different editions there have been changes in wording and requirements. Ensure that your practices meet or exceed requirements from past MUTCD rules. Under OSHA's de minimis policy, compliance with more current DOT or ANSI or other applicable nationally recognized consensus standards is acceptable (and highly encouraged) -- so long as the newer standards are at least as protective as the OSHA requirement.

A general duty clause citation [5(a)(1)] can be issued for failing to comply with 2009 MUTCD provisions.

OSHA specifically refers to consensus standard ANSI/ASSE A10.47-2009, “American National Standard for Construction and Demolition Operations: Work Zone Safety for Highway Construction.” This document can be purchased online at www.ansi.org. There is also an updated 2015 version of A10.47, but OSHA has not yet modified its CPL to reflect the newer document. Safety Priority recommends compliance with the newest version.

Compliance officers inspecting work zones where traffic speed exceeds 45 mph must be trained in work zone safety. Safety Priority offers a 1-day course, Work Zone Safety. It can be scheduled on-site or for a group by calling 1-800-809-0059.

The compliance officer will drive through the work zone and observe for potential violations, possibly from both directions, before approaching the site foreman or manager.

The compliance officer will ask to see the Traffic Control Plan (TCP). If there is no TCP prepared, the compliance officer will ask to see which MUTCD typical application(s) the work zone has been designed from, in section VI of the MUTCD. Field personnel need to be able to respond to these inquiries accurately. In addition to a TCP for traffic through the work zone, an internal TCP is recommended for construction traffic within the work zone or on the work site.

The MUTCD uses signal words of “Standard” (SHALL - mandatory), “Guidance” (SHOULD - recommended), “Option” (MAY - optional) and “Support” (information only). In assessing the work zone, the compliance officer may use both mandatory and non-mandatory provisions to identify hazards.